Directions Research, Inc. (“DIRECTIONS,” “we,” “us,” or “our”), which includes brands Aimpoint Research and SEEK Company, is a full-service custom market research firm that conducts qualitative and quantitative studies with consumers and businesses. Market research is a tool used by all sorts of organizations to obtain feedback from customers, potential customers and other stakeholders. We do business as both Directions and branded divisions known as Aimpoint Research and SEEK Company. As used herein, “DIRECTIONS” refers to Aimpoint Research and SEEK Company as well.
2. PERSONAL INFORMATION DEFINITION
3. COLLECTION OF PERSONAL INFORMATION
We collect personal information like your name and email address when you provide it to us on the our website (or otherwise) in connection with an inquiry about our services or participation in our surveys. In these cases you know what information we are collecting because you provide it to us directly.
We also collect personal information when you provide it to us in the course of participating in research, either directly to us or to a third party that conducts research services (such as surveys) on our behalf. This information includes names, email addresses, phone numbers, street addresses, unique identifiers, healthcare provider specialties and provider IDs, and demographic data, such as age, sex, race/ethnicity, parental status, marital status, ZIP code, income and education levels, employment title, financial account types, account status, and purchase behavior.
With your consent, we may also collect audio and video information as part of your participation in a survey or research project.
We may also obtain personal information from clients who ask us to conduct research on their behalf, or from list or survey panel providers. When we obtain contact personal information from third parties, we require those third parties to provide assurances that their lists are made up only of individuals who have given their permission to be included in the list, participate in the survey panel and/or be contacted for market research purposes. In such cases, we will comply with the contact limitations and data protections to which you agreed when you provided that permission. We may collect and use personal information obtained from publicly available sources, where this is permitted by law.
We will never ask you for certain information which, if stolen or misused, could give rise to economic crimes against you, such as bank account or credit card numbers, social security or other similar government-issued ID numbers.
We also automatically collect information that is made available by the device you use to access DIRECTIONS’ website, such as the date and time of your visit, device type (manufacturer and model), browser type, and IP address.
4. HOW WE USE YOUR INFORMATION
Data that is collected in connection with research is used to communicate information and insights to our clients. Specifically, the information collected in a research context may be used to plan new products or services, gauge customer satisfaction, measure awareness of products or services, or to test reaction to products, services or communications. We use demographic information, such as racial or ethnic origin, age, gender or income to help confirm that the research reflects a representative sample of the population we are studying.
If you provide personal information to us in order to inquire about our services, we will use that personal information only to contact you about our services.
If you are a respondent or potential respondent, we may also use your personal information to communicate with you, to validate your identity, and to provide you with survey opportunities we think may interest you. We use information about your device collected automatically for system administration, service improvement, data analysis, and data integrity purposes to ensure that survey respondents do not impermissibly duplicate participation in the same survey.
Otherwise we may use your personal information on an internal basis as necessary to run our company and improve our businesses.
Otherwise, we may use your personal information for any other purpose for which you have given your prior express consent.
For more details about cookies, digital fingerprinting, and tracking, see also Section 11 below.
5. HOW WE SHARE YOUR INFORMATION
We will protect your anonymity when communicating your research responses to clients. We will share your name, email address, or other contact information with its clients only with your express permission or request, or as otherwise permitted by the Insights Association Code of Standards and Ethics for Market Research and Data Analytics.
We will provide your personal information to our contractors who provide support services to us in its execution of marketing research surveys, but only to perform such functions on our behalf and for our purposes under confidentiality agreements or other appropriate confidentiality assurances. In such cases, we will share only the minimum personal information necessary and maintain liability for those data processors.
Whether we obtain your personal information directly, through a contractor performing services for us, or from a third party, we will not use this information to sell you any goods or services and we will not provide your personal information to any other party so that they may contact you for the purpose of selling you goods or services.
We may, itself or through a contracted third party, occasionally re-contact you to validate your participation in a research study; We will identify itself or be identified by the third party and we will state its purpose when we conduct such validation contacts.
The device information automatically collected may be shared with third party service providers for the purposes of detecting and preventing impermissible duplicate participation in the same survey.
Otherwise, we may share your personal information as required by law or in the interest of protecting or exercising the legal rights of us or others, including, for example and without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your personal information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business.
Your participation in research is voluntary. You are entitled at any stage of the interview or survey, or afterward, to ask that part or all of your personal data be destroyed. Wherever reasonable and practical, or required by applicable law, we will carry out such a request. Should you wish to opt-out of any survey please notify us as provided in the “Contact Us” section below or through the mechanism provided in the survey invitation.
You may access the personal information we hold about you in order to correct, amend, or delete that information where it is inaccurate by contacting us as provided in the “Contact Us” section below.
We take reasonable precautions to protect your personal information from loss, unauthorized access, disclosure, alteration and destruction.
9. DATA INTEGRITY AND PURPOSE LIMITATION
Personal information collected by us is relevant for its intended purpose and, to the extent necessary, reasonable steps are taken to ensure data is reliable for its intended use, accurate, complete and current.
As a general matter, we keep personal information for no longer than necessary for the purposes for which the personal information is collected or processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
12. THIRD PARTY SITES AND EXTERNAL LINKS
13. INFORMATION FOR INDIVIDUALS IN EUROPE
If you are visiting our websites or participating in one of our research studies from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States.
Certifying adherence, makes DIRECTIONS subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. It also means the possibility, under certain conditions, you could invoke binding arbitration as described in the frameworks.
Depending on how we obtain your personal data (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data. If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including in the United States (“US”) or other countries. It may also be processed by staff operating outside the US or the EEA who work for us or for one of our suppliers. If your personal data is transferred to, stored at or otherwise processed in a country or territory outside the EEA, and that country or territory has not been recognized as providing an adequate level of data protection, we will put in place additional safeguards to protect your personal data, based on standard contractual clauses and/or the DPF.
If you are a data subject in the EEA, Switzerland, or UK, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to separate entities to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
You may exercise your rights by contacting us as provided below. We may request specific information from you to help us confirm your identity and process your request. If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.
We will not process your personal data unless we have a lawful basis for processing. As further described above, our lawful bases include where: (a) you have given your consent to our processing for a specific purpose; (b) processing is necessary for the performance of a contract with you or to comply with a legal obligation; or (c) processing is necessary for the purposes of the legitimate interests pursued by Vital Findings or a third-party controller, including our clients.
14. INFORMATION FOR INDIVIDUALS IN CALIFORNIA
YOUR RIGHT TO “KNOW” AND TO REQUEST DELETION
You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.
You also have the right to request deletion of personal information we have collected or maintain. Please note, however, that our deletion of your personal information may negatively affect our ability to provide you with services.
To exercise these rights please contact us as provided below.
To verify your identity, we may request, at point of submission of your request, that you supply your basic contact information, as well as certain other non-personally identifiable information (e.g., information relating to your last interaction with us, such as subject matter and type of study), and we endeavor to match at least two pieces of this information with information in our possession.
Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.
YOUR RIGHT TO OPT OUT OF THE “SALE” OF YOUR INFORMATION
We will never disclose personal information such as your name or address to third parties in exchange for monetary consideration without your consent.
However, CCPA also defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.” Under this broad definition, certain information we provide to our clients as part of survey results may arguably be deemed a “sale” of “personal information” under CCPA.
You have the right to opt out of this “sale.” For more information on how to opt out, please click here: directionsresearch.com/dnsmpi.html.
PERSONAL INFORMATION “SOLD” OR DISCLOSED FOR A BUSINESS PURPOSE
As further described in the section above titled “How We Share Your Information,” in the last 12 months we have disclosed, subject to confidentiality agreements, the following categories of personal information with our third-party service providers and data collection partners: respondent names, email addresses, phone number, street address, and unique identifiers; respondent audio and video footage; demographic data, such as age, sex, race/ethnicity, parental status, marital status, ZIP code, income and education levels, employment title, HCP specialty, financial account types, account status, and purchase behavior; HCP prescriber identity; and client or prospective client contact PII, and prior purchase history with us.
Under the CCPA’s broad “sale” definition, we’ve also “sold” the following categories of personal information to our clients as part of research results: unique identifiers; any personal information provided in your survey answers; and demographic data, such as age, sex, race/ethnicity, parental status, marital status, ZIP code, income and education levels, employment title, HCP specialty, financial account types, account status, and purchase behavior.
YOUR RIGHT TO NON-DISCRIMINATION
You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services.
We do not discriminate financially between those who elect to supply their personal information to us and those who elect to not do so, provided, however, that to the extent a survey or other research study, the completion of which would result in the payment of a financial incentive, involves the collection of data and you decline to consent to such collection, you would not be able to proceed to participate in the study, and (depending on the specific study) to the extent you are required to supply your contact information at the conclusion of a survey in order for us to fulfill the participation incentive and you decline to provide your contact information, you would not receive the participation incentive.
YOUR RIGHT TO USE AN AUTHORIZED AGENT
You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In addition to verifying your identity as described above, we may also require the agent to also supply written authorization from you to act on your behalf, except where restricted by law.
We operate in compliance with the Children’s Online Privacy Protection Act (“COPPA”), governed by the US Federal Trade Commission (“FTC”). We do not collect, use or disclose information from children under the age of 13 online without a statement of permission from a parent or guardian. We also do not “sell” (as defined in CCPA) personal information of persons under 16 without affirmative authorization. For more information on COPPA, please visit http://www.ftc.gov/ogc/coppa1.htm.
16. DO NOT TRACK
Currently, our systems do not respond to browser do-not-track signals, and do not treat such do-not-track signals as “do not sell” signals under CCPA.
17. CONTACT US
Write to us at:
Directions Research, Inc.
401 East Court Street
Cincinnati, OH 452025
We have further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Data Privacy Framework Principles and the UK Extension to the EU-U.S. DPF to the INSIGHTS ASSOCIATION DATA PRIVACY FRAMEWORK SERVICES, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information and to file a complaint.
Last Updated: 9/26/2023